Privacy Policy

Who is responsible

HushThrive SRL is the controller for personal data processed about visitors to this website and about the people who hold Kooga accounts. Our details are at the bottom of this page.

For the personal data inside your workspace, such as your own customers and subscribers, you are the controller and we act as your processor, following your instructions and the terms of our agreement with you.

What we process

We keep this as small as the service allows.

• Account data: name, email address, password hash, workspace name and role.
• Billing data: plan, billing interval, invoices and the payment identifiers our payment provider returns. We never see or store your full card number.
• Usage data: which features you used and how much of each allowance you consumed, so we can meter plans and support you.
• Technical data: IP address, browser and device information, and error logs, kept for security and diagnostics.
• Workspace content: the sites, catalogues, documents, contacts and conversations you connect or create. This is yours and we process it only to run your workspace.

Why we process it, and on what basis

Each purpose has a lawful basis under the GDPR.

• To provide the service you signed up for, on the basis of performance of a contract.
• To bill you and keep accounting records, on the basis of a legal obligation and performance of a contract.
• To secure the service, prevent abuse and debug faults, on the basis of our legitimate interest in a service that works and is not abused.
• To send service messages about your account, on the basis of performance of a contract. To send marketing email, on the basis of your consent, which you can withdraw in one click.
• To meet requests from authorities where the law requires it, on the basis of a legal obligation.

Who else sees it

We use a small number of processors to run the service, and we share only what each one needs. These include cloud hosting and database providers, our email delivery provider, our payment provider, and the AI model providers that generate content and answers.

We do not sell personal data. We do not share it for advertising. Our model providers are contractually prevented from training on the data we send on your behalf.

A current list of processors is available on request to privacy@kooga.io.

Transfers outside the EEA

Some of our processors operate outside the European Economic Area, primarily in the United States. Where that happens the transfer is covered by the European Commission's standard contractual clauses or an adequacy decision, together with technical measures such as encryption in transit and at rest.

How long we keep it

Account and workspace data is kept while your account is open. When you close your account we delete or anonymise it within 90 days, except for records we are required to keep by law, such as invoices, which are retained for the period Romanian accounting rules require.

Technical logs are kept for a short period for security and diagnostics, then deleted.

Your rights

Under the GDPR you can ask us to do any of the following, free of charge.

• Access the personal data we hold about you and receive a copy.
• Correct anything inaccurate or incomplete.
• Delete your data, where we are not required to keep it.
• Restrict or object to processing based on our legitimate interests.
• Receive your data in a portable, machine readable format.
• Withdraw consent at any time, without affecting processing that already happened.

How to exercise them

Write to privacy@kooga.io. We will answer within one month. If you are not satisfied with our response you have the right to complain to the Romanian supervisory authority, the National Supervisory Authority for Personal Data Processing (ANSPDCP), or to the authority in your own country of residence.

Cookies

We use the cookies that are necessary to keep you signed in and to remember your workspace and language. We use a small amount of privacy respecting analytics to understand how the site is used. We do not use advertising cookies and we do not track you across other websites.

Children

Kooga is a business tool and is not intended for anyone under 16. We do not knowingly collect data from children. If you believe a child has given us data, write to privacy@kooga.io and we will remove it.

Changes to this policy

If we make a material change we will tell account holders by email before it takes effect, and update the date at the top of this page.